Facts:

On December 19, 1952, a criminal complaint was filed by the Chief of Police of Bacolor, Pampanga, against Francisco Quizon, the petitioner, in the Justice of the Peace Court. The complaint charged Quizon with damage to property through reckless imprudence, with the alleged damage valued at P125.00. Quizon subsequently filed a motion to quash the complaint, arguing that under Article 365 of the Revised Penal Code, the potential penalty for the offense could range from a fine of P125.00 to P375.00, which exceeded the jurisdictional limit of the Justice of the Peace Court. The Justice of the Peace Court forwarded the case to the Court of First Instance of Pampanga, which, however, returned the case to the Justice of the Peace Court for trial, asserting that the latter had jurisdiction. Quizon appealed this ruling to the Supreme Court, raising a question of law regarding the jurisdiction of the Justice of the Peace Court in relation to the charges against him.

Issue:

1. Does t...

Facts:

1. Criminal Complaint: On December 19, 1952, the Chief of Police of Bacolor, Pampanga, filed a criminal complaint against Francisco Quizon in the Justice of the Peace Court, charging him with damage to property through reckless imprudence. The damage amounted to P125.00.
2. Motion to Quash: Quizon filed a motion to quash, arguing that under Article 365 of the Revised Penal Code, the penalty for the offense could range from P125.00 to P375.00, which exceeded the fine that the Justice of the Peace Court could impose.
3. Jurisdictional Dispute: The Justice of the Peace forwarded the case to the Court of First Instance of Pampanga, but the latter returned it, holding that the Justice of the Peace Court had jurisdiction. Quizon appealed this ruling to the Supreme Court.
4. Legal Provisions:
   • Section 44 of the Judiciary Act of 1948 grants Courts of First Instance jurisdiction over criminal cases where the penalty is imprisonment for more than six months or a fine exceeding P200.00.
   • Section 87 of the same Act gives Justices of the Peace jurisdiction over criminal cases arising under laws relating to malicious mischief.

Issue:

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Ruling:

• (Unlock)

Ratio:

1. Nature of Malicious Mischief: Malicious mischief requires a specific intent to cause damage, which is incompatible with negligence. Article 327 of the Revised Penal Code explicitly requires deliberate intent to cause damage, making it impossible to commit malicious mischief through negligence.
2. Distinction Between Wilful and Negligent Acts: The Court emphasized that wilful crimes (like malicious mischief) and negligent acts (like reckless imprudence) are fundamentally different. Criminal negligence is treated as a quasi-offense, penalizing the mental attitude behind the act rather than the act itself.
3. Jurisdictional Limits: The Judiciary Act of 1948 grants Justices of the Peace jurisdiction over specific offenses, including malicious mischief, but does not extend this jurisdiction to cases of damage to property through negligence. The penalty for reckless imprudence (up to P375.00 in this case) exceeds the P200.00 limit for Justice of the Peace Courts.
4. Legislative Intent: The Court concluded that the Legislature did not intend to include negligent acts under the jurisdiction of Justices of the Peace when it granted them authority over malicious mischief.

Concurring and Dissenting Opinions

• Concurring (Montemayor, J.): While agreeing with the majority, Montemayor expressed dissatisfaction with the law, noting that it is illogical to allow Justices of the Peace to handle more serious wilful crimes but not less serious negligent acts.
• Concurring (Reyes, A., J.): Reyes concurred, emphasizing that the Court's duty is to apply the law as written, not to legislate by extending jurisdiction beyond what is explicitly granted.
• Dissenting (Jugo, J.): Jugo argued that damage to property through negligence should be punishable and that the majority's interpretation would leave such acts unpunished. He cited previous cases where negligent damage was treated as a crime.

Conclusion:

The Supreme Court granted the writ of certiorari, reversing the order of remand to the Justice of the Peace Court and holding that jurisdiction over the case lies exclusively with the Court of First Instance.